The Monetary Authority of Macao (AMCM) has imposed significant new controls on life insurers and intermediaries that use referral partners, effective 20 November under Circular No. 022/B/2025-DSG/AMCM.
The rule introduces a mandatory pre-notification process requiring insurers and intermediaries to submit detailed business plans before launching any client-referral arrangement.
Firms must disclose information about their referrers, business scale, and compliance measures, then wait through a 15-working-day review period. If the AMCM does not raise questions within that window, approval is deemed granted, but the regulator retains the power to conduct on-site inspections or request additional information.
According to law firm MdME, which analysed the circular, the regulator’s move signals heightened concern over risks associated with referral activities and significantly tightens operational and oversight standards across the market, placing greater accountability on insurers and intermediaries.
Under the new requirements, companies must perform ongoing due diligence on referrers, clearly define their limited roles, and ensure that they do not engage in regulated insurance sales. Insurers must also establish “red flag” detection systems to monitor potential misconduct, such as rising complaint volumes or high policy lapse rates, and promptly report any illegal activities to the AMCM.
Additionally, sales of life policies, particularly those with non-guaranteed returns, must now be conducted one-on-one for at least 45 minutes to ensure that clients fully understand the product. Referrals will also trigger post-sale verification, requiring an independently recorded call to confirm that clients recognise the referrer’s role and have received proper disclosure.
Furthermore, policies generated under referral arrangements must be issued in Macau and cannot be converted to those governed by other jurisdictions.
While the measures increase operational complexity, they are designed to strengthen transparency and foster a more trustworthy insurance market, according to MdME.
